1

Supporting Statement for a Request for OMB Review 

under The Paperwork Reduction Act

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection 

EPA’s Safer Choice Product Recognition Program

ICR Numbers: EPA ICR No. 2302.03 OMB Control No. 2070-0178

1(b) Short Characterization / Abstract

This renewal information collection request (ICR) addresses the submission of applications to 

EPA for recognition under the Safer Choice Product Recognition Program (Safer Choice program), 

formerly known as the Design for the Environment Program. The Safer Choice program recognizes 

products where all ingredients meet EPA’s stringent requirements for human health and the 

environment as found in the Safer Choice Standard. Under the encouragement of the current program, 

leading companies have already made great progress in developing safer, highly effective chemical 

products. Since the program’s inception in 1997, formulators have been using the program as a portal 

to OPPT’s unique chemical expertise, information resources, and guidance on greener chemistry. Safer 

Choice partners enjoy Agency recognition, including the use of the Safer Choice label on qualifying 

products. This ICR would enable Safer Choice to accommodate participation by more than nine 

formulators each year, enhance program transparency, and further promote chemical safety.

Safer Choice participates in the development of CleanGredientsTM, a database of safer cleaning 

product ingredients, which identifies safer formulations and makes forming partnerships easier. 

Organized by product functional use class (e.g., surfactants, solvents, etc.), CleanGredientsTM 

facilitates a green marketplace where formulators can select functionally appropriate and safer 

ingredients.

The redesign of chemical products offers opportunities to:

 Remove hazardous chemicals from formulations before they can enter the workplace, home, or 

environment.

 Advance energy and water efficiency, resource conservation, and innovative technologies. 

 Qualify for environmentally preferred product status, increasingly sought by government, 

retailer and consumer purchasers.

Companies formulate products from a broad range of chemicals with a variety of applications. 

The Safer Choice program labels cleaning and other chemical-based products such as dish detergents, 

laundry detergents, hand soaps, and all-purpose cleaners for consumer and industrial use. Cleaning 

products make up the majority of partnership products, and cleaning product manufacturers have the 

greatest demand for program participation by potential partners. Third-party profilers review all 

product applications prior to Safer Choice submission.

The review team carefully reviews each product component. A literature review, and when 

appropriate, structural activity relationships, are used to understand each chemical’s health and 
 2

environmental characteristics. The review includes all chemicals, including those in proprietary raw 

material blends, which ingredient suppliers share with Safer Choice and the third-party profilers in 

confidentiality. The review team then compares an ingredient’s characteristics to other chemicals in the 

same use class, considers possible negative synergies between ingredients, and places the ingredient on 

a continuum of improvement relative to other similar chemicals. By means of its review team and 

methodology, Safer Choice provides information to formulators that helps them select from among the 

safest chemicals in an ingredient class. Only formulations containing exclusively safer ingredients are 

recognized by Safer Choice.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Authority for the Safer Choice program derives from Section 6604(b)(5) of the Pollution 

Prevention Act (PPA), 42 U.S.C. 13103(b)(5) (see Attachment A), which directs EPA to facilitate the 

adoption of source-reduction techniques by businesses, and the Toxic Substances Control Act (15 

U.S.C. 2601 et seq.), which encourages safety in technological innovation in chemistry. In recognition 

of this statutory directive, and through consultation with a broad range of stakeholders, EPA developed 

the Safer Choice program.

Safer Choice program information collection activities will assist the Agency in meeting the 

goals of the PPA by providing resources and recognition for businesses committed to promoting and 

using safer chemical products. In turn, the Safer Choice program will help businesses meet corporate 

sustainability goals by providing the means to, and an objective measure of, environmental 

stewardship. Investment analysts and advisers seek these types of measures in evaluating a 

corporation’s sustainability profile and investment worthiness.1 It is not surprising then that EPA has 

heard from many organizations that Safer Choice program partnership is an important impetus for 

prioritizing and completing the transition to safer chemical products. The Safer Choice program is also 

needed to promote greater use of safer chemical products by companies unaware of the benefits of 

such a change.

Safer Choice has carefully tailored its request for information, and especially the Safer Choice 

program application forms, to ensure that it only asks for information essential to verifying applicants’ 

eligibility for recognition.

2(b) Practical Utility/Users of the Data

The information collected by the Safer Choice program is not designed or intended to support 

regulatory decision-making by EPA. EPA uses the information collected in the Safer Choice program 

application to: (1) review products and their components; (2) complete chemical profiles for each 

product component to determine its key health and environmental characteristics; and (3) establish a 

partnership agreement with the company outlining how the company and EPA/Safer Choice will work

together to continually improve the health and environmental profile of the product(s).

 

1

“Green to Gold: How Smart Companies use environmental strategy to innovate, create value, and build competitive 

advantage" by Daniel Esty and Andrew Winston, Yale University Press, New Haven, 2006
 3

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication

Respondents will not be asked to provide information that has been or is currently being 

collected by EPA, other federal or state agencies, or proprietary sources. The information collected by 

the Safer Choice program is unique and is not duplicative of previous information collection requests. 

As due diligence, EPA also checked with trade associations and potential partners to confirm that the 

information being collected by the Safer Choice program does not exist elsewhere.

3(b) Public Notice Required Prior to ICR Submission to OMB

In proposing to renew this ICR, EPA provided a 60-day public notice and comment period that 

ended on May 9, 2016 (81 FR 12097, March 8, 2016). EPA received no comments during the 

comment period.

3(c) Consultations

Additionally, under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an ICR to OMB for 

review and approval. In accordance with this regulation, EPA submitted questions to three parties via 

e-mail. The individuals contacted were:

Kathleen Stanton, Director

Technical and Regulatory Affairs

American Cleaning Institute

KStanton@cleaninginstitute.org

Beth L. Law, Assistant General Counsel

Vice President, Stewardship & Sustainability

Consumer Specialty Products Association

BLaw@cspa.org

Bill Balek, Director

Legislative & Environmental Services

ISSA - The Worldwide Cleaning Industry Association

bill@issa.com

EPA received no responses to its solicitation for consultations. A copy of EPA’s consultation email to the above potential respondents is included in Attachment E.

3(d) Effects of Less Frequent Collection

Safer Choice program applications will be received on an ongoing basis over the three years 

covered by this ICR. The applications are designed to be one-time information submissions for 

organizations that wish to participate in the Safer Choice program, with the opportunity to renew the 

partnership agreement at the end of the three-year partnership period. This means that once every three 

years, the organization will submit a renewal application to confirm that no changes have been made to 

ingredients; this step is done in response to correspondence from Safer Choice that reminds 
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organizations of the terms of their partnership agreements. Without this information collection 

mechanism, Safer Choice will not have the ability to assist formulators in developing safer, highly

effective chemical products or to formally recognize formulators who have successfully done so.

3(e) General Guidelines

The information collection activities discussed in this renewal ICR comply with all regulatory 

guidelines under 5 CFR 1320.5(d)(2).

3(f) Confidentiality

Some information collected by EPA under the Safer Choice program involves confidential 

business (CBI) or trade secret information. The Safer Choice program handles all information claimed 

as confidential business information in accordance with Agency confidentiality procedures (see 40 

CFR part 2, subpart B). The Safer Choice program uses information provided by formulators solely for 

purposes related to forming the partnership and discloses the information only to EPA employees and 

EPA contractors cleared for confidential information with a specific need to know.

3(g) Sensitive Questions

The information collection activities does not involve any sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The Safer Choice program seeks partners from establishments engaged in the formulation of 

end-use, for-sale chemical products.

Below is a list of representative North American Industry Classification System (NAICS) codes 

and associated industries that may be affected by information collection requirements covered under 

this ICR. This list is intended to be illustrative; entities from other industries may elect to apply for 

recognition through the Safer Choice program. However, EPA expects that most applications will 

come from the following industries:

NAICS Code Affected Industry

325510 Paint and Coating Manufacturing

325611 Soap and Other Detergent Manufacturing

325612 Polish and Other Sanitation Good Manufacturing

325910 Printing Ink Manufacturing

325992 Photographic Film, Paper, Plate, and Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

4(b) Information Requested

Once a company with an interest in partnership with the Safer Choice program reviews the 

program materials and decides to apply, the next step for the organization is to submit the appropriate 

application.
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(i) Data items:

Applicants for this voluntary program submit information items that vary depending upon the 

class of product. The items include:

Partnership Applications

Product manufacturers will submit ingredient information, as described here, through a cloudbased Salesforce system, to a qualified third-party profiler before submittal to EPA (see Attachment 

B).

Information submitted to third-party profilers:

 Company name and Web site URL;

 Number of employees;

 Company headquarters address and manufacturing address;

 Name, title, phone number, and e-mail address of the candidate’s signatory contact person

(e.g., CEO, or vice president for health and environment);

 Name, title, phone number, and e-mail address of candidate’s technical contact person;

 Name, title, phone number, and e-mail address of candidate’s marketing/outreach contact 

person;

 Product information (name(s), UPC, GSA number, sector, production volume, pH, 

flashpoint, product form, product use);

 Product characteristics on whether or not the product is:

o An EPA registered pesticide;

o A direct release product;

o A concentrate;

o Contains enzymes, fragrance, or VOCs;

o Requires hazard labeling;

o Ingredient disclosure and performance data submitted;

 Packaging information:

o Container size and shapes;

o Material;

o Supplier;

 Description of all chemical ingredients, including raw materials and alternative ingredients, 

in product:

o CAS number;

o Chemical name;

o Trade name;

o Percent composition;

o Ingredient class;

o Supplier name;

 An SDS for the product and each ingredient;

 Product performance testing (any method of demonstrating product performance is 

acceptable as long as it is a commonly used industry standard);

 Other product information specific to particular product classes, such as flushability / 

compostability for disposable cleaning wipes;

 If available, any supplemental product or ingredient environmental health and safety 

information, such as:
 6

o Biodegradation tests on individual ingredients;

o Acute aquatic toxicity tests on product as a whole or individual ingredients;

o Human health and safety tests;

 Description of the type of training the company provides to customers on environmental 

and worker safety matters.

Information submitted to EPA:

 Summary report, containing same data items as above.

Adding Third-Party Partners and Products

Cleaning product manufacturers will submit information about third-party additions to Safer 

Choice through their third-party profiler. The three types of third-party partners and products are 

private labels, licensees, and toll manufacturers. To be label-eligible, third-party products must contain 

ingredients identical to those in a Safer Choice-labeled product.

Information submitted to EPA:

 Safer Choice Form for Adding Third-Party Partners and Products (Private Label 

Companies, Licensees, or Toll Manufacturers) (EPA Form XXXX-X) (See Attachment C)

Note that this form will be incorporated into the Salesforce system in the coming months. The 

fields in the online form in Salesforce will be identical to the PDF form. Until this part of the 

system is fully incorporated, the Agency will continue to use the PDF application form in 

Attachment C.

(ii) Respondent activities:

Applicants for Cleaning and Non-Cleaning Product Formulation Partnerships

 Review program information, including instructions on submitting information to thirdparty profilers (note: third-party profilers are separate and distinct from third-party partners 

and products; a third-party profiler is an organization that has partnered with the Safer 

Choice Program to assist in the evaluation of product formulations against the Safer Choice 

Standard. To become a third-party profiler, the organization must meet stringent 

requirements as laid out in Section 7 of the Safer Choice Standard.)

 Submit information described in section 4(b)(i) of this supporting statement to third-party 

profiler;

 Establish agreement with third-party profiler;

 Submit summary report to Safer Choice;

 Negotiate / establish Partnership Agreement with Safer Choice;

 Renew partnership, with no changes needed;

 Site audit (See Attachment D).

Adding Third-Party Partners and Products

 Review program information;

 Fill out and submit Safer Choice Program Form for Adding Third-Party Partners and 

Products (Private Label Companies, Licensees, or Toll Manufacturers).
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5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under the Safer Choice program, EPA engages in the following activities related to the 

Formulator application and decision process:

 Provide applications via Salesforce for potential participants;

 Answer questions posed by potential applicants regarding recognition under the program;

 Receive the completed applications, review for accuracy, and place any necessary follow-up 

calls;

 Apply EPA’s chemical tools and expertise to understand toxicological characteristics of 

chemical ingredients and to ensure that they are the safest within their functional use class;

 Approve candidates for recognition and notify both successful and unsuccessful applicants of 

the decisions; and

 Make final decisions about which products may carry the Safer Choice label.

5(b) Collection Methodology and Management

Product manufacturers may obtain applications for providing ingredient information by 

contacting a third-party profiler. The third-party profiler will then coordinate with EPA to direct the 

potential applicant to a link via Salesforce to complete the application online. If a product 

manufacturer would like to submit information that they believe is Confidential Business Information 

as defined under the Toxic Substances Control Act, the applicant should contact EPA by phone.

In collecting and analyzing the information associated with this ICR, EPA will use a telephone 

system, personal computers, and applicable database software such as Salesforce. EPA will ensure the 

accuracy and completeness of collected information by reserving the right to request proof of the list of 

ingredients (e.g., bills of lading, invoices) or other relevant documentation at any time to confirm that 

candidates have the achieved the criteria for recognition. The cloud-based Salesforce system, which 

houses applications and other information related to the Safer Choice program, is designed to reduce 

the public and Agency burden related to the application and decision process. However, if a product 

manufacturer would like to submit information as a hard copy rather than using the Salesforce system, 

the applicant should contact EPA for the appropriate forms.

5(c) Small Entity Flexibility

EPA expects that some of the participants in the Safer Choice program will be small entities. 

EPA has designed its application form to minimize respondent burden while obtaining sufficient and 

accurate information. In addition, given the voluntary nature of the collection, EPA expects that 

respondents will participate only if the benefits of participation outweigh the information collection 

burden.

5(d) Collection Schedule

Organizations may submit an application for recognition at any time.
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

The average respondent burden is estimated to be 16 hours for new product formulators and 8

hours for product formulators wishing to add third-party partners and products (see Exhibit 6.2). EPA 

used professional judgment to arrive at a burden estimate and then consulted representatives from the 

participant categories to make sure the burden estimates were reasonable (see section 3(c)).

EPA expects that for a typical product formulator, program and application review will take 

about 2 hours (1 managerial, 1 technical). Filling out and submitting third-party profiler information 

request forms will take about 6 hours (5 technical, 1 clerical), and then establishing an agreement with 

the third-party profiler will take about 3 hours (1 managerial, 1 technical, 1 clerical). Submitting a 

summary report to Safer Choice will take about 2 hours (1 managerial, 1 technical). Finally, 

establishing a Partnership Agreement with Safer Choice will take 3 hours (1 managerial, 2 technical).

For a typical addition of a third-party partner and products, program and application review 

will take about 2 hours (1 managerial, 1 technical). Filling out and submitting one Safer Choice 

Program Form for Adding Third-Party Partners and Products (Private Label Companies, Licensees, or 

Toll Manufacturers) is estimated to take about 2 hours (1.5 technical, 0.5 clerical). On average, a 

partner will fill out 3 third-party partners and products forms annually. Therefore, it is estimated that it 

will take one respondent 6 hours (4.5 technical, 1.5 clerical) to add third-party partners and products.

In addition to the burden associated with first-time submission of applications, each formulator 

has the opportunity to renew its Partnership Agreement at the end of the three-year partnership period. 

This means that once every three years, the formulator re-submits its application for each partnership 

product to confirm that no changes have been made to ingredients. EPA then evaluates the application. 

EPA estimates that the partnership renewal process will take 4 hours (3 technical, 1 clerical) for 

cleaning and non-cleaning product formulators.

For purposes of this ICR, EPA expects that 108 (see Section 6(e) on estimating the respondent 

universe) product formulators will choose to renew their partnerships. Furthermore, EPA anticipates 

that one in ten product formulators (i.e., 12) over the three-year period of this ICR will need to make 

improvements to their formulations so that they contain the safest ingredients within each functional 

use class; in these cases, a new partnership approval process, as described above, will be triggered. The 

associated burden for completing the new partnership approval process is assumed to be the same as 

first-time submission.

As part of the application process, the third-party profiler will also reserve the right to conduct 

site audits and desk audits. The purpose of site visits to facilities is to verify that each partnership 

product contains the same ingredients, in the same volumes, that are reported by the company as part 

of the Safer Choice recognition process. The site auditor will review batch tickets associated with each 

recognized product to ensure that ingredient claims are accurate. Additional audit procedures are listed 

in Attachment D of this document. For purposes of estimating annual cost and burden in Exhibit 6.2, it 

is assumed that about 33% of formulators will get audited on-site each year over the three-year period 

of this ICR. Each site audit is estimated to require two hours of a technical person’s time and one hour 

of a clerical person’s time. Desk audits will also be conducted by third-party profilers. Prior to the desk 

audit, formulators will be responsible for providing a list of all ingredients for each recognized 

product, product labels displaying the Safer Choice logo, private label information (where applicable), 
 9

and various other materials. For the purposes of estimating annual cost and burden in Exhibit 6.2, it is 

assumed that 66% of formulators will be subject to a desk audit each year over the three-year period of 

this ICR. Each desk audit is estimated to require two hours of a technical person’s time and two hours 

of a clerical person’s time. As with the site audits, additional information on desk audits can be found 

in Attachment D of this document.

6(b) Estimating Respondent Costs

EPA estimates an average loaded hourly labor rate (base hourly rate plus fringe and overhead) 

of $83 for managerial staff, $73 for technical staff, and $32 for clerical staff. These three labor rate 

estimates are based upon manufacturing industry wage data from the Bureau of Labor Statistics (BLS) 

Employer Costs for Employee Compensation, Supplementary Tables from September 2015. The 

hourly labor rates include a 17% overhead; this overhead rate is used for consistency with OPPT 

economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics 

Release Inventory Program2and the Revised Economic Analysis for the Amended Inventory Update 

Rule: Final Report.

3

In addition, the hourly labor rates have been rounded for the purposes of this ICR. 

The type of staff needed to complete the Formulator’s applications and their associated hourly labor 

rates were verified by contacting representatives from the participant categories.

The derivation of labor rates for managerial, technical, and clerical staff appears in Exhibit 6.1.

Exhibit 6.1. Derivation of Loaded Wage Rates in 2015$

Labor 

category

Wage Fringe 

Benefit

Fringes as 

% wage

Overhead

% wage

Fringe + 

overhead 

factor

Loaded 

Wages

Loaded 

Wages 

(rounded) (a) (b) (c)=(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a)  (e)

Managerial4 $49.78 $24.70 49.62% 17% 1.67 $82.94 $83.00

Professional/

Technical2

$42.76 $23.07 53.95% 17% 1.71 $73.10 $73.00

Clerical2 $19.04 $9.61 50.47% 17% 1.67 $31.89 $32.00

In exhibit 6.2 is the breakdown of burden costs, assuming 16 hours for completing the 

partnership agreement, 11 hours for renewals and associated audits, and 8 hours for cleaning product 

formulators wishing to add third-party partners and products. The third-party profiler verification 

process for cleaning products also adds an operating and management (O&M) cost of about $12,400

per company per application. This cost estimate is from NSF International, which has experience as a 

third-party profiler of ingredient characteristics. For this ICR, it is assumed that typical product 

manufacturers will submit four products in an application. Each product is assumed to contain 2 

ingredients at $650 each, 1 proprietary ingredient at $1,300 each, and 3 CleanGredientsTM ingredient at 

no charge, for a total of $2,600 per product. In addition, a $500 administrative fee per product is 

 

2 EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Wage Rates 

for Economic Analysis of the Toxics Release Inventory Program. Washington, DC: June 10, 2002.

3 EPA, 2002. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised 

Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.

4 Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables. From 

Supplementary Table 2, Employer costs per hour worked for employee compensation and costs as a percent of total 

compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and 

bargaining status, September 2015. Available at: http://www.bls.gov/ncs/ect/sp/ecsuptc36.pdf
 10

assumed. The total will be $12,400 per company per application. No additional capital or O&M costs 

are incurred by respondents under this ICR.
 11

Exhibit 6.2. Estimated Annual Burden and Costs to Respondents

Collection activity

Hours and Costs Per Respondent Total Hours and Costs

Managerial Technical Clerical Response 

Hours/Year

Labor 

Cost/Year

Capital O & M 

Cost*

Number of 

Respon.**

Total 

Hours/Year

Total 

$83/Hour $73/Hour $32/Hour Cost Cost/Year

Partnership Agreements

Review program information

1.0 1.0 - 2.0 $156 $0 $0 44 88 $6,864

Fill out and submit third-party 

information request form - 5.0 

 

1.0 6.0 $397 $0 $0 44 264 $17,468

Establish agreement with thirdparty profiler 1.0 1.0 

 

1.0 3.0 $188 $0 $12,400 44 132 $553,872

Submit summary report to Safer 

Choice 1.0 1.0 - 2.0 $156 $0 $0 44 88 $6,684

Negotiate / establish Partnership 

Agreement with Safer Choice 1.0 2.0 - 3.0 $229 $0 $0 44 132 $10,076

Subtotal

 4.0 10.0 2.0 16.0 $1,126 $0 $12,400 44 704 $595,144

Renewals and Audits

Renew partnership, with no 

changes needed - 3.0 

 

1.0 4.0 $251 $0 $0 36 144 $9,036

Desk audit

- 2.0 2.0 4.0 $210 $0 $0 24 96 $5,040

Site audit

 - 2.0 

 

1.0 3.0 $178 $0 $0 12 36 $2,136

Subtotal 

- 7.0 4.0 11.0 $639 $0 $0 36 276 $16,212

Adding Third-Party Partners and Products

Review program information

 1.0 1.0 - 2.0 $156 $0 $0 77 154 $12,012

Fill out and submit form for 

adding third-party partners and 

products - 4.5

 

1.5 6.0 $377 $0 $0 77 462 $28,991

Subtotal

 1.0 5.5 1.5 8.0 $533 $0 $0 77 616 $41,003

TOTAL 157 1,596 $652,359

* The cost for third-party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four products, each with 2 

ingredients ($650 each), 1 proprietary ingredient ($1,300), and a $500 administrative fee. The total cost per product is $3,100. The total will be $12,400 per company per application.

**This column reports the number of annual respondents after accounting for the partnership renewal process. Assumes that one in ten formulators over the three-year period will 

need to make changes to their formulations and go through a new partnership process which includes same collection steps. On an annual basis, this translates to 4 product 

formulators (for a total of 44 partnership agreements). Also assumes that about 33% of the remaining product formulators will be subject to site audits each year (i.e., 12) and that 

about 66% (i.e., 24) will be subject to desk audits each year. See Section 6(a) for additional explanation. Assumes that 77 partners will fill out third-party partners and products forms

based on historical data. See Section 6(e) for additional explanation.
 12

6(c) Estimating Agency Burden

Exhibit 6.3 presents the estimated Agency burden hours and costs associated with the 

information collection activities under this ICR. EPA based its burden estimates on its 

experience managing other voluntary programs.

EPA expects that review of the program application forms for a typical product 

formulator will take about 1 hour (1 technical). Reviewing the third-party profiler information 

summary report will take about 5 hours (5 technical). Establishing a Partnership Agreement 

with the formulator will take about 3 hours (1 managerial, 2 technical). Reviewing the 

partnership renewal and assuming that no changes are needed is estimated at 2 hours (1 

managerial, 1 technical), and reviewing audit summaries is estimated at 1 hour (1 technical).

The burden for reviewing the Safer Choice Form for adding third-party partners and 

products is estimated to take about 2 hours (2 technical).

6(d) Estimating Agency Costs

Agency labor costs are calculated based on hourly basic rates for federal employees in 

the Washington-Baltimore area published by the Office of Personnel Management effective 

January 20165. The average hourly labor rate for managerial staff is estimated as the rate for a 

GS-13 Step 5 employee, for technical staff as a GS-10 Step 10 employee, and for clerical staff 

as GS-5 Step 1. These GS-level assumptions are consistent with those used in past EPA OPPT 

ICRs. The hourly rates were multiplied by an assumed loading factor of 1.6 to reflect Federal 

fringe benefits and overhead. This loading factor is from an EPA guide, Instructions for 

Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9).

The resulting average hourly labor rates, rounded to the nearest dollar amount, are $80 

for managerial staff, $59 for technical staff, and $27 for clerical staff. The Agency expects 

most activities related to this ICR to be performed by managerial staff (14 percent) and 

technical staff (86 percent).

 

5 OPM, 2016. Salary Table 2016-DCB, Washington Baltimore Northern Virginia, DC-MD-PA-VA-WV. 

Available at http://www.opm.gov/oca/16tables/pdf/dcb_h.pdf
 13

Exhibit 6.3. Annual Agency Burden/Cost 

Collection activity

Hours and Costs Per Respondent Total Hours and Costs

Managerial

$80/Hour

Technical 

$59/Hour

Agency 

Hours/Year

Labor 

Cost/Year

Capital/ 

Startup Cost

O & M 

Cost

Number of 

Respon.*

Total 

Hours/Year

Total 

Cost/Year

Cleaning and Non-Cleaning Products

Review program application 

forms - 

 

1.0 1.0 $59 $0 $0 44 44 $2,596

Review third-party profiler 

summary - 5.0 5.0 $295 $0 $0 44 220 $12,980

Negotiate / establish Partnership 

Agreement with formulator 1.0 

 

2.0 3.0 $198 $0 $0 44 132 $8,712

Review partnership renewal, 

with no changes needed 1.0 

 

1.0 2.0 $139 $0 $0 36 72 $5,004

Review audit summaries

- 1.0 1.0 $59 $0 $0 36 36 $2,124

Subtotal

 2.0 10.0 12.0 $750 $0 $0 80 504 $31,416

Adding Third-Party Partners and Products

Review Safer Choice form for 

adding third-party partners and 

products - 2.0 2.0 $118 $0 $0 77 154 $9,086

Subtotal

 - 2.0 2.0 $118 $0 $0 77 154 $9,086

TOTAL 157 658 $40,502

*This column reports the number of respondents after accounting for the partnership renewal process. Assumes that one in ten formulators will need to make changes to their 

formulations and go through a new partnership process which includes same collection steps, i.e. 4, for a total of 44 annually. Assumes that 77 partners will fill out third-party partners and 

products forms based on historical data. 
 14

6(e) Estimating the Respondent Universe and Total Burden and Costs

EPA estimates that 120 formulators will submit applications over the three-year life of 

the clearance. EPA expects the participation will ramp up over the three year period but, for the 

purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that 40 product 

formulator applications will be submitted each year. This estimate is based on historical data and 

the assumption that participation will increase over the next three years in response to greater 

consumer demand for safer products and increased awareness of the Safer Choice label. EPA 

also expects 40 renewals per year, 10% of which will need to make changes to formulations and 

go through a new partnership process. Additionally, EPA estimates that 77 applications will be 

received annually to add third-party partners and products. This estimate is based on the average 

number of partners that submitted third-party partners and products applications over the past 

five years (62) and is expected to increase over the course of this ICR period due to the new label 

(25%). Therefore, it is estimated that a total of 157 respondents will submit applications under 

the Formulator program each year. The annual burden hours and cost associated with this 

information collection are 1,596 hours and $652,359 respectively.

6(f) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Exhibit 6.4 below summarizes the total annual estimated respondent burden and cost. 

These estimates represent the average burden in any given year over the three years covered by 

this ICR.

Exhibit 6.4. Total Annual Estimated Respondent Burden and Cost Summary

Total # of Respondents Total Burden Hours Annual Cost

157 1,596 $652,359

b. Agency Tally

Exhibit 6.5 below summarizes the total annual estimated agency burden and cost. These 

estimates represent the average burden in any given year over the three years covered by this 

ICR.

Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Cost

658 $40,502

6(g) Reasons for Change in Burden

This request reflects an increase in the estimated annual burden of 362 hours (from 1,234

hours to 1,596 hours) from that currently in the OMB inventory. EPA reduced per-response 

burden estimates compared to those in the previous ICR based on expected efficiencies created 

by using the Salesforce-based Safer Choice Community on the part of respondents. However, the 
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number of respondents increased, compared to the prior ICR, due to historical experience and 

increases in the expected future number of responses due to greater consumer awareness and 

demand for products with the Safer Choice label. This change is an adjustment.

6(h) Burden Statement

The annual public burden for this collection of information is estimated at 16 hours per 

response for formulators, 11 hours for formulators renewing a partnership that requires changes,

and 8 hours for cleaning product formulators wishing to add third-party partners and products, 

including time for reviewing instructions, gathering information, and completing and reviewing 

the application. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for EPA’s regulations in title 

40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included 

on the related collection instrument or form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPPT-2015-0437, which is available for online viewing at www.regulations.gov, or in person 

viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 

NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the 

Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention and 

Toxics Docket is (202) 566-0280. You may submit comments regarding the Agency's need for 

this information, the accuracy of the provided burden estimates and any suggested methods for 

minimizing respondent burden, including the use of automated collection techniques.

Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2015-0437 and 

OMB Control No. 2070-0178, to (1) EPA online using www.regulations.gov (our preferred 

method), or by mail to: Document Control Office (DCO), Office of Pollution Prevention and 

Toxics (OPPT), Environmental Protection Agency, Mail Code: 7407T, 1200 Pennsylvania Ave., 

NW, Washington, D.C. 20460, and (2) OMB by mail to: Office of Information and Regulatory 

Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th 

Street, NW, Washington, DC 20503.
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ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the Supporting Statement are available in the public docket established 

for this ICR renewal under docket identification number EPA-HQ-OPPT-2015-0437. These 

attachments are available for online viewing at www.regulations.gov or otherwise accessed as 

described above in Section 6(h) of the Supporting Statement.

Attachment A: 42 USC 13103 - Pollution Prevention Act Section 6604

Attachment B: Safer Choice Program: Product and Ingredient Submissions in 

Salesforce

Attachment C: Safer Choice Program: Form for Adding Third-Party Partners and 

Products (Private Label Companies, Licensees, or Toll 

Manufacturers)

Attachment D: Safer Choice Program: Audit Process Guidance

Attachment E: Copy of Consultations Message Sent by EPA to Potential Respondents